Featured Articles:

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an approximately $7.8 million civil penalty for 9,256 violations of the Global Terrorism Sanctions Regulations (“GTSR”). SITA provides telecommunications services to companies in the civilian air transport industry.  Membership in SITA is open to industry operators worldwide...

Cardinal Health Pays SEC $8.8 Million for FCPA Violations

Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records.  (SEC Order Here).  Cardinal acknowledged facts relating to internal controls deficiencies and its handling of marketing accounts that it supervised for its distributors.  In particular, while Cardinal mitigated its corruption risks by terminating many of these accounts, Cardinal inaccurately assessed the...

Admit It – Your Compliance Program is Not Really “Effective”

Chief compliance officers are heroes.  They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs. CCOs live by a credo – they risk-rank and prioritize all their activities (hopefully) on an ongoing basis.  It is a job similar to our cats and dogs chasing their own tails – they will...

Episode 129 — How to Create a Third-Party Risk Profile

Companies continue to refine their third-party risk management programs.  As an initial step, companies have to create a third-party risk profile for its population.  To accomplish this task, companies have to classify and stratify their third parties. In this episode, Michael Volkov discusses how to review your third-party population and create a risk profile.

The Impact of a New CEO

Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts.  These changes have a significant impact on the business, its operations, its risk profile and eventually its success or failure to adapt. We often hear about the significant impact of a...

Incident Data and Intra-Company Cooperation

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained in its recent Evaluation of Corporate Compliance Programs issued on April 30, 2019. DOJ prosecutors have seen it all when it comes to compliance.  Prosecutors have observed compliance train wrecks – companies that have suffered...

Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia

In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia.  A copy of the indictment is here. The three former executives included: Reza Moenaf, the former president of Alstom’s Indonesia subsidiary; Eko Sulianto, the former director of sales of Alstom’s Indonesia subsidiary; and...

The Volkov Law Group is Hiring — Junior Associate and Paralegal

The Volkov Law Group is offering a great opportunity for a junior associate and a paralegal. The Volkov Law Group is a nationally-recognized boutique law firm that offers a variety of services, including criminal defense, securities compliance and defense, and ethics and compliance services, including anti-corruption, export and sanctions compliance, anti-money laundering, due diligence and internal investigations. As a leader in ethics and compliance and enforcement defense,...

Wells Fargo Settles With Justice Department for $3 Billion

This year, 2020, has been an enforcement year opening with billion-dollar settlements: first, Airbus settled FCPA charges for $4 billion, and now Wells Fargo for $3 billion.  What a start to an enforcement year! We all have heard about the Wells Fargo debacle, and I have written repeatedly about Wells Fargo’s blatant misconduct.  Wells Fargo has defined itself as a company lead by rotten senior...

Episode 128 — Compliance Automation and Program Measurement and Evaluation

Companies are rapidly implementing automated solutions for compliance program functions.  Technology accelerates compliance program performance and creates opportunities to measure and evaluate a company’s compliance program. In this Episode, Michael Volkov discusses how to measure and evaluate a compliance program using data generated from automated platforms.